Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Waiver of interest u/s 220(2) – all the three conditions were to some extent satisfied, and the refusal of CCIT to grant reduction in interest is not justified - partial relief granted - HC
Waiver of interest u/s 220(2) – all the three conditions were to some extent satisfied, and the refusal of CCIT to grant reduction in interest is not justified - partial relief granted - HC
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